• Incident Date: February 2, 1997.
• Victim's Death: Due to head injuries caused by blunt and sharp-edged weapons.
• Discovery: Deceased's body was found in the verandah of Mohan Singh's shop on February 3, 1997.
• Accusations: Appellants allegedly murdered the deceased due to prior enmity linked to 1996 Panchayat elections.

2. Prosecution Evidence

• Based on circumstantial evidence, including the following:
  • Last seen with the accused.
  • Motive due to past enmity.
  • Recovery of items near the crime scene (meat bag and blood-stained stone).

3. Trial Court Findings

• Convicted appellants under Section 302/34 IPC (murder with common intention) and Section 201 IPC (causing disappearance of evidence).

4. High Court's Partial Reversal

• Altered conviction to Section 304 Part I IPC (culpable homicide not amounting to murder).
• Reduced sentence from life imprisonment to 7 years rigorous imprisonment.

Supreme Court Findings

Legal Principles on Circumstantial Evidence

1. Circumstances must be conclusively proven.
2. Circumstances must point only towards the guilt of the accused.
3. The chain of evidence must exclude all other hypotheses of innocence.

Analysis

Motive

• Though enmity was proven, no direct evidence linked the enmity to the crime.

Last Seen Theory

• Time gap (16 hours) between the deceased being last seen and recovery of the body.
• No proximity between the places where the deceased was last seen and where the body was found.

Recovery of Items

• Meat bag and stones found near the crime scene could not be conclusively linked to the accused.

Discovery Statement (Section 27 of Evidence Act)

• Statements inadmissible as recovery of incriminating items occurred before the disclosure.

Judgment

• Ratio Decidendi: In a case based on circumstantial evidence, a conviction cannot stand unless the prosecution establishes a chain of evidence that is complete, credible, and excludes every hypothesis of innocence.
• Decision: Acquittal of appellants. High Court and trial court findings overturned.

Relevant Acts and Sections:

1. Indian Penal Code (IPC)

   • Section 302: Punishment for murder.
   • Section 304 Part I: Culpable homicide not amounting to murder (with intent to cause death).
   • Section 201: Causing disappearance of evidence.
   • Section 34: Common intention.

2. Indian Evidence Act, 1872

   • Section 27: Admissibility of discovery statements.

3. Code of Criminal Procedure, 1973 (CrPC)

   • Section 313: Examination of accused.

Subjects:

Criminal Law, Circumstantial Evidence, Acquittal.
Evidence Act, Indian Penal Code, Motive, Last Seen Theory, Section 27 Evidence Act, Acquittal, Chain of Circumstances, Reasonable Doubt.